State v. WeddingtonAnnotate this Case
At issue was under what circumstances a defendant has properly invoked his right to request a discharge of counsel pursuant to Maryland Rule 4-215(e).
The Court of Special Appeals vacated Defendant’s convictions because the circuit court failed to hold a Rule 4-215(e) hearing prior to Defendant’s trials. Before trial, Defendant sent two pieces of correspondence to the circuit court in which he expressed dissatisfaction with his counsel. The circuit court did not take action on either correspondence until after Defendant’s trials. After the trials had concluded, the circuit court denied Defendant’s request. The Court of Appeals affirmed the judgment of the Court of Special Appeals, holding (1) Defendant’s two letters to the circuit court sufficiently triggered Rule 4-215(e); (2) Defendant did not waive his request to discharge his counsel when he did not repeat his request prior to or during his trials; and (3) the circuit court committed reversible error when it failed to inquire into the reasons for Defendant’s request in a timely manner.